In May 2013, the U.S. Department of Health and Human Services’ Office of Inspector General (OIG) issued a Special Advisory Bulletin concerning excluded individuals and entities. Within the advisory bulletin, the first in over a decade, the OIG alerted organizations receiving federal funding from Medicare that it is highly recommended that they monitor the OIG’s List of Excluded Individuals and Entities (LEIE) on a monthly basis in order to minimize their liability from civil monetary penalties.

On September 30, 1999 the U.S. Department of Health and Human Services’ Department of Inspector General released a Special Advisory Bulletin on The Effect of Exclusion from Participation in Federal Health Care Programs. The brief document set off a deluge of questions and requests for clarification on critical policy guidelines in the fourteen years following its release.

OIG Issues Special Advisory Bulletin Regarding Exclusion Sanction Checks on Individuals and Entities

The US Department of Health and Human Services (DHHS), Office of Inspector General (OIG) released a "Special Advisory Bulletin on the Effect of Exclusion from Participation in Federal Health Care Programs" on May 8, 2013—the first in over ten years. The OIG originally published a Special Advisory Bulletin in September 1999. What does this mean for your organization's sanction screening practices? The updated 2013 bulletin expands the OIG's exclusion authority.

FCRA Compliance: What Employers Need to Know Before Running Background Checks

As an employer relying on a third party to run background checks on job candidates or existing employees, you must follow the federal Fair Credit Reporting Act (FCRA). Your responsibilities are detailed in the document entitled “Notice to Users of Consumer Reports: Obligations of Users under the FCRA.” Below is a breakdown of your essential duties under the Act. If you have any questions, consult qualified counsel.

GSA - EPLS Exclusion Database Changing to SAM

For many years, PreCheck and the National Healthcare Data Bank (NHDB) have utilized the General Services Administration (GSA) Excluded Parties List System (EPLS) on a daily basis to determine whether an individual or entity is excluded. The EPLS is a federal database containing the names of those individuals and entities that have been barred and excluded from doing business with the federal government.

Sanctions vs. Board Actions

In the world of healthcare the terms Sanctions and Board Actions are commonly used but often misunderstood. Sanctions and exclusions are actions taken by state and federal agencies with sanctioning authority against an individual or entity. Usually, the individual is a licensed healthcare professional. A Board Action, however, is an adverse action taken by a state licensing board against a healthcare professional's license.

Implementation of a strong sanction and exclusion screening program is just one of the various tools you rely on to ensure patient safety and program compliance. Further, conducting sanction screening protects your organization from civil monetary penalties. The requirement to check the names of employees, medical providers, and suppliers against the federal OIG and GSA exclusion lists seems pretty straightforward. Yet, you know that just checking the OIG Exclusions List is not enough.

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